The Environment Agency has today warned people to be prepared for flooding as it launches its Flood Action Campaign. The likely effects of climate change, with more frequent and intense flooding, are emphasised.
Oxford City Council’s Planning Review Committee met last night to reconsider the application to extend Seacourt park and ride. This had previously been approved by West Area Planning Committee but a review had been requested by concerned councillors.
The review committee confirmed the previous decision.
There is a report in the Oxford Mail.
We believe this decision is a huge mistake and we are disturbed by aspects of the decision-making process.
There is no lack of parking spaces here, nor overall. Should it ever be needed, better usage of existing parking could easily be achieved by live signage on the ring road. We have collected online data and visited the site over the very busy pre and post Christmas periods – the existing car park has never once been full. Opening of the new Westgate has not caused problems and many people clearly choose to drive into the city rather then use park and ride.
The cost is huge, £4.1 million is already budgeted. And there are many other urgent calls on the public purse. People are homeless and sleeping on the streets just a mile away.
The site floods from groundwater – an aspect that has received scant attention, despite our highlighting it repeatedly. Because of groundwater flooding there will be a net loss of floodplain if this development goes ahead. The site will also flood when the rivers flood. This will make it expensive to pump out, maintain and repair.
The decision is undoubtedly contrary to national planning guidance (NPPF) which is there to protect the floodplain and Green Belt. A previous extremely similar application on the site was the subject of a Planning Enquiry in 1998 and refused by the Secretary of State in 1999. Since 2007 the guidance has been strengthened following the Pitt Report on the Oxford and nation-wide flooding in 2007.
It is possible that the present application will be Called-in by the present Secretary of State for Communities and Local Government, Sajid Javid: we have requested, jointly with Layla Moran MP, that this should happen. If the application is Called-in a Public Enquiry will follow. The reason for our request is that a decision to develop a car park in the floodplain sets a serious national precedent. Building in the floodplain is deplorable, except in the most exceptional cases – which this most certainly is not.
If the extension does eventually go ahead it is not impossible that the Council will in time come to regret it – as construction costs rise, maintenance is expensive due to recurrent flooding (exacerbated by climate change) and occupancy is low. But that will be no comfort – much better it should never happen in the first place.
Today there are Environment Agency Flood Alerts for our area. As we write, water from ditches to the west is starting to accumulate in a corner of King George’s Field, behind Duke and Earl Streets, as it does at the start of every flood. More rain is forecast tonight.
And on the very same day we read of opposition to the Oxford Flood Alleviation Scheme in the Oxford Mail. The Scheme is designed to save many, many hundreds of homes and businesses from recurrent flooding, at enormous stress, disruption, and financial cost – to individuals, families, businesses, and the whole Oxford community. Climate change is widely expected to make things far worse in the future. We’ve been at this for ten years now and in our opinion (and that of many others) there is no viable alternative, “Green” or otherwise. If we don’t get the Oxford Flood Alleviation Scheme it’ll simply be a disaster for Oxford.
Why do we need a flood scheme at all?
We have had five major floods since 2000 and climate change will make things worse (indeed there is evidence from Oxford University that it already has). Oxford residents, and the economic well-being of the City, will suffer badly if something is not done. While the scheme will cause disruption during its construction it is imperative that Oxford is protected.
But what about downstream, won’t they be worse off?
All the detailed computer modelling for the Scheme (and we have recently heard on the grapevine that a totally independent consultancy has confirmed this ) says that flooding will not be made worse downstream. We know that comparisons are made with the Jubilee River – this scheme is nothing like that. Indeed OFAS is actually increasing the capacity of the floodplain, which together with bunding and rerouting of flow will reduce flood risk to many hundreds of properties.
Is it a concrete channel?
No, it isn’t. What it is is a much more naturalistic 2-stage channel, used around the world for flood relief.
How will the environment be affected?
While there will, regrettably, be some environmental losses, we are pressing hard – collaborating with the Environment Agency, and with support from others, particularly the Freshwater Habitats Trust – for environmental enhancements as part of the scheme. While one cannot compare one environmental loss directly with another environmental gain we believe the positives will be considerable.
It’s so important that there is a plan now for the very long-term maintenance of the Scheme. In our experience over the last 10 years “if maintenance can be neglected it probably will be”. There are some honourable exceptions and we certainly have we have no criticism whatever of the local EA maintenance team, who achieve a huge amount with very limited resources. Others do nothing or very little unless goaded and embarrassed into action. This Scheme, being “natural” will deteriorate quickly if not proactively maintained. The initial intent was to plan maintenance for 10 years: that is simply not good enough for such an expensive and important project. We have proposed that maintenance be planned for in perpetuity by setting up a responsible, funded, local body, maybe as a charitable trust (or similar).
A Green group
thinks that Oxford could and should be protected by very different means – while they are short on specifics, their main idea seems to be that planting enough trees upstream in the Cotswolds would solve Oxford’s problems. It wouldn’t. Expert opinion at our 2015 Symposium of Natural Flood Management (NFM) made that very clear. Even afforesting the whole of the Cotswolds (not that that would ever happen) would not do the job. Oxford is simply too far downstream for that. That’s not to say that NFM can’t work in smaller catchments, nor that it might not make a contribution.
Flooding land upstream?
The Environment Agency’s Oxford Flood Risk Management Strategy (OFRMS) suggests this may be needed one day if climate change makes things sufficiently bad. Involving as it would temporary flooding large areas of farmland and other land it is never likely to be easy to implement.
National planning policy framework (NPPF) guidelines strongly recommend against the positioning of developments that are categorised (in this case according to the Environment Agency) as ‘less vulnerable’, in Flood Zone 3b, functional floodplain.
Sir Michael Pitt’s report on the severe and widespread summer floods of 2007 said there should be ‘a presumption against building in high flood risk areas in accordance with PPS25’ [now NPPF] (Pitt Review; ‘Implementation and Delivery Guide, 2008: Final Recommendation 7). The guidance should be ‘kept under review and strengthened if and when necessary’ (Final Recommendation 8).
The title of Sir Michael Pitt’s report is ‘Learning Lessons from the 2007 Floods’. This development is far from being essential and NPPF should be adhered to. To do otherwise would set a very dangerous precedent.
The Planning Statement for the application to extend Seacourt P&R states (para. 6.74):
” Consideration was given at an early stage in the design development to provision of a decked car park on the existing P&R site. This is not feasible because the existing P&R site is not within the Applicant’s freehold ownership and there is a legal covenant on the land which prohibits the construction of any buildings…”
That is to say, the rationale for an extension being needed, as opposed to raised decking on the existing car park, is that there is a covenant on the existing car park land which prevents the latter. We have asked the applicant if we can see the reported covenant but no such has been produced. Nor can we find one on searching the Land Registry. What we have been shown is an extract of what seems to be a form of lease agreement (not a covenant) on the existing car park. Such an agreement could potentially be varied by negotiation with the landlord.
Letter from us published in the Oxford Times of 8 December 2016
The proposed extension to Seacourt Park & Ride is one of the worst planning proposals we’ve seen for some time. In 2013, after much public consultation, the City Council adopted a Core Strategy to guide development in the city over the next period. Core Strategy 2 includes the statement: “Greenfield land will not be allocated for development if any part of the development would be on Flood Zone 3b.” The proposed extension to the Park & Ride is a greenfield site in Flood Zone 3b, the functional flood plain. How can this be? The planning documents don’t explain. Although the documents include a review of relevant local policies, Core Strategy 2 mysteriously doesn’t get a mention. What’s driving the application is a worry about short-term problems with traffic congestion on the Botley Rd pending completion of new Park & Rides at Eynsham and Cumnor. How does this short-term need justify departing from core strategy? National planning policy is designed to encourage local authorities to take a strategic approach to planning, thereby avoiding the need for this kind of last minute quick-fix nibbling away at the floodplain.
Apart from the obvious conflict with planning policy, the application is riddled with errors. The Flood Risk Assessment says that the most recent flooding event at the site was 2008, ignoring the major disruption in the winter of 2012/13, and the serious floods in early 2014. The FRA completely fails to take account of the fact that the site floods frequently, and proposes a design which will quickly degrade as a results of flood damage and silting. There is serious risk in the event of a major flood of large sections of the car park breaking up and washing into the flood channel. It’s a nonsense and needs to be stopped.
The first image is a part of a plan, from the Environment Agency, of the proposed Oxford Flood Alleviation Scheme (OFAS) north of the Botley Road. This shows (as at 16 September 2016) that a key flood defence bund is planned for that scheme, running through the area where the car park extension is proposed.
The second image shows the area for the proposed extension to the Seacourt P&R.
It is not clear that the bund and the car park extension could co-exist. OFAS will reduce the risk of flooding in Oxford, vital for people and the future prosperity of the city, not least in the face of climate change. The car park extension proposal is flawed in many ways; the plan should be dropped.
We have made further comments (our fourth) on the Seacourt P&R planning application to the Planning Officer today, 19 December 2016:
Planning Application 16/02745/CT3
We wrote to you earlier with regard to the validity of the so called ‘sequential test’ carried out for the Seacourt P&R extension. In addition to our previous argument about the existence of an option of negotiating with the landlord to erect decking on the current site, we have further grounds for objection to the ‘sequential test’.
The City Council Executive Board papers for 15 December 2016 include proposals for removing 270 parking spaces at Redbridge to accommodate a new waste transfer facility. It appears there is excess capacity at Redbridge P&R. The analysis of occupancy of Redbridge and Seacourt P&Rs included in the Executive Board papers, show that there is existing spare capacity at Redbridge, and but for the planned waste facility this could relieve Seacourt during the week. There is also capacity at both car parks sufficient to adsorb expected increases in weekend traffic once the Westend development completes.
The Planning Statement for the Seacourt extention makes no mention of the surplus capacity available at Redbridge. The review of Redbridge in the ‘sequential test’ simple says that there is limited scope to ‘expand’ Redbridge. This is deeply misleading. There is clearly scope to redirect surplus traffic from Seacourt to Redbridge, which might be achieved at no cost simply by use of differential pricing – i.e. making Seacourt more expensive. In the Seacourt application we’re told Seacourt has to expand because there isn’t an option at Redbridge. But the Redbridge proposal is using the possible expansion of Seacourt to justify closing parts of Redbridge. So the need to expand Seacourt is at least in part being created by the Council’s wish to re-purpose part of the Redbridge site. This is clearly an unacceptable justification for the Seacourt extending into the floodplain on Green Belt land.
Given the existence of sufficient capacity to deal with any increased weekend traffic related to the Westend, the arguments for the extension, contained in 3.20 of the Planning Statement, appear extremely general. Is this really the best justification the Council can offer for breaching its own core strategy, national policy on Green Belt, and guidance on development in the floodplain? The justification for this move appears to rely wholly on longer term projections about potential increases in traffic resulting from a growth in the city and county during the next 15 years. Such needs should be addressed through a strategic planning process.
We understand that the Council has to increasingly rely on the revenue it earns, and perhaps the real, unstated reason why this proposal has come forward is financial. But even this doesn’t make sense. The capital cost has now doubled from the original budget to £4.1m. Extra income from the extension, assuming rates increase from £2 to £3 a day, is projected at £160,000 a year according to the Executive Board papers. Even assuming this revenue is achievable the investment would take more than 26 years to pay back, and that is without discounting for the cost of capital. If, as we believe is likely, the site floods regularly, has to be closed part of the year, and faces significant maintenance costs, the payback period will be much longer.
This scheme is a nonsense and should not proceed.
We have submitted a further comment (our third), this time on the proposed porous paving, to the planning authority today. You can download it here.